Compliance

Preparing for an audit

The audit program for Exhibited Animals allows the Department to verify that licensees are complying with the Exhibited Animals Protection Act 1986 and Exhibited Animals Protection Regulation 2010. The audit and compliance program also assures the industry that a robust system is in place which maintains the integrity of the industry, is consistently applied, and is risk based.

The aim of this document is to provide both Compliance Officers and licensees with a consistent information and understanding of the audit process. This guidance document can also be used by licensees to understand why defects are identified during audits, and the severity of potential defects.

All Exhibited Animals authority holders are audited against the Exhibited Animals Protection Act 1986 and Exhibited Animals Protection Regulations 2010 and Standards.

Most exhibiting facilities are required to comply with requirements specified in clauses of the regulation (19-39) as well as the prescribed standards.

Guiding principles when we audit

The requirements of all the standards and legislation relate to three main outcomes:

• Animal welfare
• Public safety
• Educational benefit.

These three outcomes are used as the guiding principles for the audit program and assessment of the industry.

The audit process

An audit is a process where an authorised auditor visits a facility or display site to assess compliance. During the audit the auditor carries out an inspection of the facility/site and reviews documentation (including procedures, work instructions and monitoring records).

During a licensing or compliance audit, the authorised officer will check that the licensee is:

• Conducting activities permitted on the certificate of licence
• Adhering to the licence conditions and legislative requirements
• Managing the security and safety of visitors and staff
• Managing animal welfare
• Providing educational benefit
• Maintaining current and accurate records

The auditor has a list of areas that must be checked and use a checklist to document evidence of compliance or non-compliance.

Before leaving the facility, the auditor will ask himself/herself the question: ‘Is the licensee managing the display of animals in a manner that is safe and that complies with the relevant standards and conditions of licence?

If the auditor does not have confidence that licence conditions are being met, he/she will:

• record an unacceptable audit outcome
• implement appropriate compliance action, supported by evidence available at the time of the audit.

Corrective Action Requests (CAR)

If the auditor identifies an area that is not compliant, he/she will raise a corrective action request (CAR).

A CAR identifies the non-compliance, and generally allows the licensee a period of time to take action to address the issue.

The CARs identified during audits are rated as minor, major or critical, depending on their severity. Each CAR attracts a numerical value, the total of which determines the overall audit outcome.

Table 1. Corrective Action Request Scoring

When deciding what rating to apply to a non-conformance, an auditor will take into account:

• The degree of risk asociated with the non-conformance.
• The overall standard of the exhibit, the animal welfare systems in place, and animal welfare and public safety culture of the business.
• Overall compliance and non-conformance history of the exhibit e.g. is it a recurring issue?
• The exhibitor’s ability and attitude to taking corrective action in response to the non-conformance.

The auditor will use a guide to help categorise CARs.

Minor CAR

A minor CAR is a non-conformance which threatens neither the effectiveness of, nor the assurance provided by, the audit program.

Minor non-conformances are generally administrative or technical in nature and are low risk to the effective operation of the system.

Major CAR

A major CAR is a non-conformance where there is a significant breakdown in the implementation or documentation of controls, which threatens the effective operation of systems.

Critical CAR

A critical CAR is a non-conformance which, in the opinion of the authorising authority, seriously threatens the effectiveness of the systems or controls in place and has, or will, have an impact on human safety or animal welfare.

Table 2 is a guideline for CARs raised in audits, based on existing knowledge and data, and are typically the main areas of risk. It should be noted however that these are guidelines only and are intended to be used in conjunction with other available resources and the professional judgement and knowledge of the auditor.

Table 2: Non-conformance categorisation guidelines

CAR Escalation Policy

If an exhibitor does not rectify any CAR or defect identified during an audit within the required timeframe, the original CAR can be reissued (with increased audit points),  and a further CAR issued for failure to comply with the original CAR. This will result in a worse audit result.

Audit results

At the conclusion of the audit, the allocated points for each CAR are added to give a total rating for the business, from an ‘A’ to an ‘E’ rating.

Table 3. Audit rating

Unacceptable audit result

If an authority holder receives an unacceptable audit result:

• remedial action may be required
• immediate corrective action may be required with specific timeframes for compliance
• conditions may be imposed that restrict or prohibit certain activities by the licensee or permit holder
• the licence may be suspended, cancelled or not renewed or not granted
• individuals or companies may receive penalty notices or be prosecuted.

Table 4. Timing of follow-up audits

Unannounced audits

Routine audits will generally be carried out on an announced basis, however unannounced or unscheduled audits may be carried out. These audits can be in response to complaints, other matters requiring investigation or to monitor compliance.

Communication

The auditor will document the audit, all findings and CARs raised in an audit report. This report will generally be completed while the auditor is on site.

The auditor will discuss the findings, any non-conformances identified, and expected timeframes to correct the non-conformances.

The audit report will be sent to you, either as hard copy or electronically.

If you have any questions regarding the findings contained in the audit report, it is recommended you contact the auditor to discuss, before your next audit.